National Pollutant Discharge Elimination System Permit B P Products North America Whiting Refinery
Agenda Public MeetingDraft NPDES Permit forBP Products • Opening Remarks • Presentation of the changes at the Whiting Business Unit by BP • Presentation of the draft NPDES permit by IDEM • Break, collection of questions from the audience • Response to questions submitted by the audience • Closing Remarks
Introduction • The public comment period for the draft NPDES permit is open until May 11, 2007. • Written comments addressing the draft permit will be accepted up to May 11, 2007. • All written comments will be considered by IDEM in the preparation of the final permit. • All written comments will receive a response from IDEM.
Introduction • The B P Products NPDES permit/Fact Sheet are available on the internet at: http://www.in.gov/idem/permits/water/wastewater/public_notice/index.html. • Please write out all questions and comments that you wish to have addressed at this Public Meeting on the form provided. • Questions will be addressed following this presentation.
Facility Description • BP Products North America Inc. owns and operates a petroleum refinery located on approximately 1,700 acres in Whiting, East Chicago and Hammond, Indiana near the southern tip of Lake Michigan. The refinery employs approximately 1,500 people and produces a variety of products including gasoline of all grades, diesel fuel, heating fuel, jet fuel, asphalt and coke. The refinery can process up to 420,000 barrels of crude oil per day.
Receiving Waters • Lake Michigan – Lake Michigan is the receiving water for Outfalls 001 and 002. (Outfall 001 will be renumbered as Outfall 005 with commencement of discharge through effluent diffuser). • Lake George Branch of the Indiana Harbor Ship Canal – The Lake George Branch of the Indiana Harbor Ship Canal is the receiving water for Outfalls 003 and 004
Lake Michigan • Lake Michigan is designated as an outstanding state resource water, Lake Michigan is also designated for full-body contact recreation and capable of supporting a well-balanced warm water aquatic community. The Indiana portion of the open waters of Lake Michigan is designated as salmonid waters and shall be capable of supporting a salmonid fishery.
Lake George Branch of the IHSC • The Lake George Branch of the Indiana Harbor Ship Canal is classified as a high quality water that is a tributary to an OSRW (Lake Michigan) and is also designated for full-body contact recreation and capable of supporting a well-balanced warm water aquatic community.
Outfall 001 • BP Whiting discharges a maximum monthly average of 21.4 million gallons per day of treated wastewater from water used in the refinery, recovered ground water and most of the storm water from the site through their wastewater treatment plant to Outfall 001.
Outfall 001 cont. • BP also accepts and treats wastewater at the wastewater treatment plant from NiSource Whiting Clean Energy (approx. 1.2 MGD) and Ineos PIB Unit (formerly BP Chemical Plant) (approx. 0.45 MGD).
Whiting Clean Energy • Whiting Clean Energy supplies BP with steam. The closed cycle cooling towers operated by Whiting Clean Energy have a blowdown which is sent to the BP wastewater treatment plant (WWTP).
Ineos • The Ineos facility sends wastewater from a polybutene manufacturing/processing unit (PIB unit) to the BP wastewater treatment plant. The PIB unit has sent their wastewater to the BP WWTP for many years.
Alternate Mixing Zone • IDEM is proposing to allow a discharge induced mixing zone through a diffuser in Lake Michigan which produces a mixing volume of lake water that is 37.1 times greater than the discharge volume of 21.4 million gallons per day from Outfall 001. • The alternate mixing zone will encompass a 182 feet radius from the diffuser.
Alternate Mixing Zone cont. • Diffuser design basics: • 330 feet long. • 12 ports facing upward. • Port diameter is 6 inches. • Ports spaced 30 feet apart. • Distance from shore is 3,500 feet. • Lake depth at diffuser is 28.5 feet.
Alternate Mixing Zone cont. • In accordance with 327 IAC 5-2-11.4(b)(4), the mixing zone shall not: • Interfere with or block passage of fish or aquatic life • jeopardize the continued existence of an endangered or threatened species or result in the destruction or adverse modification of such species’ habitats • extend to drinking water intakes • impair or otherwise interfere with the designated uses of the receiving water
Alternate Mixing Zone cont. • promote undesirable aquatic life or result in a dominance of nuisance species • allow substances to settle to form objectionable deposits • allow floating debris, oil, scum, and other matter in concentrations that form nuisances • allow objectionable color, odor, taste or turbidity, or • cause adverse effects to human health, aquatic life or wildlife.
Alternate Mixing Zone cont. • The following concerns were raised about the alternate mixing zone by IDEM’s Assessment Branch: • Toxicity of the Effluent • The support structure of the diffuser becoming an attraction to aquatic life • Maintenance of the Diffuser • Biological monitoring to ensure efficient diffuser operation.
Alternate Mixing Zone cont. • Compliance with effluent limitations and Whole Effluent Toxicity testing requirements will ensure that the discharge after mixing does not demonstrate toxicity to aquatic life. • Approval of the design of the support structure is under the jurisdiction of the IDNR Division of Water, US Army Corps of Engineers (Detroit District), and IDEM’s Water Quality Certification Program. • Part II.B.1 of the permit requires the permittee to maintain in good working order and efficiently operate all facilities and systems including the diffuser.
Alternate Mixing Zone cont. • Efficient diffuser operation will be ensured by proper operation and maintenance requirements under Part II.B.1. • There will be a written maintenance procedure developed by BP addressing proper operation and maintenance of diffuser. • Proper operation and maintenance will be verified through periodic inspections by BP Products and IDEM.
Alternate Mixing Zone cont. • IDEM has evaluated all available information relevant to the consideration of harm to human health, aquatic life, or wildlife, and has determined that the alternate mixing zone will not cause any of the adverse impacts identified in 327 IAC 5-2-11.4(b)(4). • Implementation of an alternate mixing zone significantly reduces the potential for BP's discharge to adversely affect aquatic life, because the magnitude and duration of exposure will be reduced as a result of more rapid and immediate mixing.
Outfall 002 • In the past, BP Whiting has discharged a maximum monthly average of 119.6 million gallons per day (11-99 through 10-01 data) of non-contact cooling water to Lake Michigan through Outfall 002. • Outfall 002 currently has a maximum monthly average discharge of 96.4 MGD of non contact cooling water (7-02 through 12-05 data). • After the refinery has been configured to process CXHO, the maximum monthly average discharge from Outfall 002 will be 81.8 MGD.
Outfalls 003 and 004 • BP Whiting discharges storm water to Outfalls 003 and 004 using a manually controlled valve. • The storm water is managed through the use of a Spill Prevention, Control and Countermeasure Plan, a Facility Response Plan, and Agreed Order No. H-11187 which defined eight interim measures to be implemented at the J & L site in which Outfalls 003 and 004 are located.
Effluent Limitations for 001 • The permit places effluent limitations on the following pollutant parameters: BOD, TSS, COD, Benzo-A-pyrene, Chloride, Copper, Total Dissolved Solids, Fluoride, Lead, Oil and Grease, Phenolics, Ammonia, Strontium, Selenium, Sulfate, Sulfide, T. Chrome, H. Chrome, Mercury, Vanadium, pH, Phosphorus and Whole Effluent Toxicity
Effluent Limitations Rationale for Outfall 001 • BP is allowed up to three years to either install and operate the diffuser or meet the final effluent limitations that are based on Indiana Water Quality Criteria calculated into effluent limitations without the benefit of the mixing zone. • Limits from the existing permit are carried forward at the same levels and will remain applicable as interim limits during the compliance period, until the diffuser is operational.
Effluent Limitations Rationale for Outfall 005 • When the diffuser becomes operational, Outfall 001 will become Outfall 005 for data tracking purposes. The actual monitoring point will remain the same. • The effluent limitations for BOD, COD, oil and grease, phenolics, Sulfide, T. Chrome, H. Chrome and pH will be identical to the effluent limitations contained in the existing permit. • Phosphorus is limited to a daily maximum concentration of 1 mg/l.
Effluent Limitations Rationale for Outfall 005 cont. • The effluent limitations for Fecal Coliform and Total Residual Chlorine have been removed from the permit because the sanitary wastewater is now being sent to the City of Whiting for treatment. • BP is required to monitor the effluent from Outfall 001 for Acute and Chronic Toxicity until the diffuser is operational and then BP will be required to monitor the effluent from Outfall 005 for chronic toxicity only. • If toxicity is demonstrated, a Toxicity Reduction Evaluation is required.
Effluent Limitations Rationale for Outfall 005 cont. • BP will be allowed up to five years to achieve compliance with the new final limitations for Vanadium and Mercury. • IDEM anticipates BP will apply for a Streamlined Mercury Variance which will require BP to implement a pollutant minimization program to reduce Mercury in their discharge. • IDEM anticipates BP will develop additional toxicological data for Vanadium which will be used to revise the water quality criterion for aquatic life.
Effluent Limitations Rationale for Outfall 005 cont. • The effluent limitations for ammonia as N and Total Suspended Solids (TSS) are being increased due to the increased loading of these pollutants to the WWTP resulting from refining the Canadian Extra Heavy Crude (CXHO) and increasing the coking capacity. BP submitted an Antidegradation Demonstration to IDEM to justify these increased permit limitations.
Antidegradation Rule for OSRWs • Discharge flow volume will not increase as a result of CHXO refining proposed by BP Products. • 327 IAC 5-2-11.7(a)(1)(B)(iv) allows the Commissioner of IDEM to calculate increased effluent limitations on a case-by case basis when the proposed increase in mass is not a result of an increase in discharge flow.
Antidegradation Implementation • IDEM required BP to submit an antidegradation demonstration which shows the increase is necessary, that the activity responsible for the increase accommodates important social or economic benefits to the area where the discharge occurs and that it is limited to the minimum necessary to allow the activity to occur.
Antidegradation Demonstration • BP will implement the following projects as part of the CXHO Project to minimize TSS and ammonia in the effluent: • Desalter Brine Treatment to remove emulsified solids from the brine wastewater prior to entering the process sewer. • Expansion of the sour water stripping system for handling the increased ammonia loading from the processing of Canadian crudes.
Antidegradation Demonstration cont. • Installation of an additional 10 million gallon equalization/storm water tank to allow more consistent feed to the WWTP. • Upgrading the final filters at the WWTP to improve hydraulics and reliability. • Implementing flow reduction projects to maintain the WWTP discharge at current level of 21.4 MGD.
Antidegradation for Ammonia • Ammonia effluent limitations Monthly Average Daily Maximum • Existing 1,030 lbs/day 2,060 lbs/day • Proposed 1,584 lbs/day 3,572 lbs/day • Fed ELGs 3,358 lbs/day 7,387 lbs/day • WQBELs 3,215 lbs/day 7,501 lbs/day
Antidegradation Demonstration for Ammonia Demonstrated ammonia removal efficiency = 70% • Existing loading of ammonia to the WWTP = 1,668 lbs/day • Estimated loading of ammonia to the WWTP using CXHO = 3,822 lbs/day • 0.3 x 3,822 lbs/day = 1,147 lbs/day • Monthly average limit based on 95% probability of achieving compliance with 1,147 lbs/day = 1,584 lbs/day using EPA guidance.
Antidegradation for TSS • TSS effluent limitations Monthly Average Daily Maximum • Existing 3,646 lbs/day 5,694 lbs/day • Proposed 4,925 lbs/day 7,723 lbs/day • Fed ELGs 4,925 lbs/day 7,723 lbs/day • WQBELs TSS does not have numeric water quality criteria.
Antidegradation Demonstration for TSS • TSS influent loading to WWTP has the potential to increase by as much as 654% based on data from another refinery which has processed the CXHO (Toledo, OH). • Proposed increase from the existing monthly average limit of 3,646 lbs/day to 4,925 lbs/day is a 35% increase. • Increase reflects the increase in the coking operations.
Antidegradation Demonstration • This project will: • Increase the diversity and security of oil supplies to the Midwestern United States • Allow the Whiting Refinery to continue to operate as a viable business and significant employer of northwest Indiana • Contribute to the tax bases of the cities of East Chicago, Whiting and Hammond • Create 70 to 80 new full time positions in the refinery and will also result in thousands of temporary construction jobs
Proposed BP Permit Limits Monthly Average • TBL WQBEL Current Draft • lbs/day lbs/day lbs/day lbs/day • BOD 6,156 N/A 4,161 4,161 • COD 42,980 N/A 30,323 30,323 • O&G 1,791 N/A 1,368 1,368 • Phenolics 32.8 N/A 20.33 20.33 • Sulfide 32.5 N/A 23.1 23.1 • Total Chromium 38.1 627 23.9 23.9 • Hex Chrom 3.13 54 2.01 2.01 • TSS 4,925 N/A 3,646 4,925 • Ammonia 3,358 3,215 1,030 1,584
Effluent Limitations Rationale for Outfall 002 • The effluent limitations for Total Organic Carbon (TOC), Total Residual Chlorine, pH and Temperature are identical to the limits in the existing permit. • Oil and Grease has the same daily maximum effluent limitation of 5 mg/l, but it is no longer a net limitation (BP no longer receives credit for amounts of oil and grease in the influent, making the proposed limit more stringent).
Effluent Limitations Rationale for Outfalls 003 and 004 • The effluent limitations for Oil and Grease, TOC and pH are identical to the limitations in the existing permit. • BP must develop a Storm Water Pollution Prevention Program within eighteen (18) months from the permits effective date.
Submit your Questions & Comments • Please complete the forms provided to submit your questions and comments. • When completed, submit the forms to a member of IDEM. • Questions will be addressed this evening, if possible. • Comments will be considered in the final permit decision.
Questions? & Comments • IDEM will now answer questions about the Draft NPDES Permit • Comments that you want IDEM to consider in the final permit decision should be submitted in writing to: IDEM - Office of Water Quality Industrial NPDES Permits Section Attention: Mr. Bill Stenner or Mr. Steve Roush MC 65-42 IGCN Room 1255 100 North Senate Avenue Indianapolis, IN 46204-2251